Case Digest (G.R. No. L-18841) Core Legal Reasoning Model
Core Legal Reasoning Model
Facts:
In Republic of the Philippines v. Philippine Long Distance Telephone Company, G.R. No. L-18841, decided January 27, 1969, the plaintiff-appellant, the Republic of the Philippines acting through its Bureau of Telecommunications (created by Executive Order No. 94 on July 1, 1947), sued the defendant-appellant, the Philippine Long Distance Telephone Company (PLDT), in Civil Case No. 35805 before the Court of First Instance of Manila. Since 1933 PLDT and RCA Communications, Inc. had operated an interconnection agreement to relay overseas telephone traffic, but in 1956 PLDT gave RCA two years’ notice to terminate. Meanwhile, from 1948 the Bureau of Telecommunications had rented 78 PLDT trunk lines to serve government and, later, private subscribers, under rules filed with the Public Service Commission. On April 7, 1958, PLDT warned the Bureau that its use of the leased trunk lines for public service violated PLDT’s regulations and threatened to disconnect them by April 12. When no co Case Digest (G.R. No. L-18841) Expanded Legal Reasoning Model
Expanded Legal Reasoning Model
Facts:
- Parties and Legal Framework
- The Republic of the Philippines, through the Bureau of Telecommunications (created by Executive Order No. 94 on July 1, 1947), authorized to operate and maintain wire-telephone and radio-telephone services, set rates subject to Department Head approval (Sec. 79 EO 94).
- The Philippine Long Distance Telephone Company (PLDT) is a public service corporation with a legislative franchise (Act 3426, as amended by Commonwealth Act 407) to operate telephone and electrical message transmission services.
- RCA Communications, Inc., under legislative franchises (Act 2178, Act 3180), maintained long-distance wireless and radio-telephone stations and contracted with both PLDT and the Bureau.
- Pre-Dispute Agreements and Operations
- PLDT–RCA agreement (1933) for automatic transfer of overseas calls, with toll-splitting arrangements (amended several times), terminable on 24 months’ notice.
- Bureau’s Government Telephone System (GTS) rented PLDT trunk lines for government use (from 1947), then extended service to the general public (since 1948) at its own rates.
- Bureau–RCA provisional agreement (from February 2, 1958; formal March 5, 1958) for joint overseas radio-telephone service.
- Severance, Litigation, and Lower-Court Proceedings
- On April 7, 1958, PLDT alleged misuse of leased trunk lines by the Bureau (serving private subscribers), warned of disconnection by April 12, 1958.
- At midnight on April 12, 1958, PLDT disconnected 78 trunk lines, isolating most foreign telephone traffic.
- The Republic filed suit in CFI Manila (Civil Case No. 35805) on April 12, 1958, seeking (a) a mandatory contract of interconnection on reasonable terms, and (b) a preliminary injunction to restore and maintain connections.
- On April 14, 1958, the court a quo issued—and later made permanent—a preliminary mandatory injunction ordering PLDT to reconnect and refrain from further severance; it dismissed both the Republic’s complaint (to compel contract) and PLDT’s counterclaims.
- Both parties appealed to the Supreme Court.
Issues:
- Can the Republic compel PLDT to enter into an interconnection contract under the contractual system?
- May the Republic, instead, invoke eminent domain to require interconnection of PLDT facilities for public service?
- Does the Court of First Instance have jurisdiction over such petition, or is the Public Service Commission (PSC) the proper forum?
- Was the Bureau of Telecommunications empowered to engage in commercial telephone operations serving the public?
- Was PLDT justified in severing the trunk-line connections it had leased to the Bureau?
- Is PLDT entitled to compensation for the use of its poles by the Bureau’s telephone wires?
Ruling:
- (Subscriber-Only)
Ratio:
- (Subscriber-Only)
Doctrine:
- (Subscriber-Only)